Dear Peter,

TRANSPORT FOR LONDON – NIGHT BUS CONSULTATION

London Councils is committed to fighting for resources for London and getting the best possible deal for London’s 33 councils. Part think-tank, part lobbying organisation, and part service provider, London Councils formulates policies, organises campaigns and runs a range of services all designed to make life better for Londoners.

London Councils welcomes the social and economic benefits that the introduction of the Night Tube will bring. We recognise that in some cases this will reduce demand on existing high frequency Night Bus services. We welcome the opportunity to comment on TfL’s proposals for changes to Night Bus service patterns and frequencies as a result of the introduction of the Night Tube.

We have provided a more detailed response to the consultation below. In summary, we want to see TfL:

- Monitoring whether it is necessary to increase the frequency of services on the proposed new routes. It should also work with boroughs (and the Police, if necessary) to address any negative impacts of people congregating at, or near, Tube stations.
- Working with boroughs to address local concerns about reduced frequencies of Night Buses in their areas, to consider less substantial reductions initially when the Night Tube begins and to keep levels of service under review once changes are made.
- Making information available to boroughs, residents and businesses on the difference in journey times between those completed using a combination of the Night Tube and Night Buses compared to those completed using existing Night Buses on the most affected routes.
- Confirming that buses operating less frequently than one bus every 10 minutes will run to a published timetable with an even interval between buses.
- Considering how many people may be put off or prevented from using the Night Tube by the additional cost and whether its fare structure could accommodate a reduced Night Tube fare for frequent night time travellers. TfL should be flexible enough to consider reintroducing Night Bus services after changes are made if demand remains high. • Undertaking an Equalities Impact Assessment of the proposals and publicising the results. • Working more collaboratively with boroughs on the issue of taxi ranks required as a result of the introduction of the Night Tube and keeping the level of provision required under review.

Yours sincerely,

Cllr Julian Bell

Chair of the London Councils Transport and Environment Committee Transport for London Night Bus Consultation – London Councils’ Response

New Services

We welcome TfL’s proposal to introduce new Night Buses that will connect communities, primarily in outer London, to Night Tube Stations. However, given that these services will only run at frequencies of one bus every 30 minutes, the proposals may lead to significant numbers of passengers congregating at, or near, Tube stations. TfL should monitor this to consider whether it is necessary to increase the frequency of services on certain routes. TfL should also work with boroughs (and the Police, if necessary) to address any negative impacts of people congregating at, or near, Tube stations. Amongst other things, this may include increases in anti-social behaviour, noise and littering.

Reduced Services

The impact of the proposals to reduce the frequency of 17 of the 117 existing Night Bus services will vary between (and in some cases within) boroughs. We note that some areas will see the frequency of services cut in their areas, despite not benefitting from the Night Tube. Examples of this include centres such Hackney, Elephant & Castle and Angel. Some boroughs also note that the roads that Night Buses travel along in their areas are not served by late night Tube services. This may be the case even if the Night Bus does serve one or more Tube stations along the bus route. We urge TfL to work with boroughs to address local concerns about reduced frequencies of Night Buses in their areas, to consider less substantial reductions initially when the Night Tube begins and to keep levels of service under review once changes are made.

Boroughs so far have highlighted concerns with the following routes:

- 94, N8, N9, N29, N38, N73, N91, N97.

It is likely that other boroughs will respond to the consultation to express concern about other routes before the deadline for comments.

In south east London, the frequency of the N1 will be reduced from every 20 minutes to every 30 minutes. The areas of south east London served by the N1 do not benefit directly from the Night Tube but will be served by the new ‘feeder’ Night Buses that will link areas to Night Tube stations, at a frequency of one bus every half an hour.

TfL’s states that its analysis ‘indicates that customers who take the tube instead of the bus for all or part of their journey will save 20 minutes on average, and in some cases up to an hour’. However, this analysis has not been made available as part of the consultation and so the impacts on specific areas cannot be considered fully. In south east London, for example, it is not possible to determine whether a combination of the Night Tube (operating at a frequency of every 10 minutes) and the new Night Buses (operating at a frequency of every 30 minutes) would improve journey times for passengers, when compared to existing Night Bus services. TfL should make this information available to enable boroughs, residents and businesses to enable them to make an informed response to the proposals.

We would welcome confirmation that buses operating less frequently than one bus every 10 minutes will run to a published timetable with an even interval between buses. Equality Implications

London Council is concerned about the impact that significant reductions in the frequencies of some Night Bus services will have on low paid Londoners and people with reduced mobility.

The higher cost of the Night Tube compared to Night Buses will require workers that use Night Buses to commute to/from work to choose between a faster but more expensive Tube service and a cheaper Night Bus service operating at a reduced frequency at weekends. For some Night Buses, the reduction in frequency is substantial, with, for example, the N20 reduced from one bus every 10 minutes to one bus every 30 minutes at weekends. TfL should consider how many people may be put off / prevented from using the Night Tube by the additional cost and whether its fare structure could accommodate a reduced Night Tube fare for frequent night time travellers. TfL should also be flexible enough to consider reintroducing Night Bus services after changes are made if demand remains high.

We are also concerned that many Tube stations do not provide step-free access from street to train. For people that rely on this, the Night Tube is not a reasonable alternative to a Night Bus, which offers better accessibility. We are not aware of an Equalities Impact Assessment of the proposals having been carried out and released with the consultation. TfL should undertake one and publicise the results.

Taxis

We understand that TfL has recently written to a number of boroughs regarding the impact of the Night Tube on taxi ranks and has identified preferred locations for additional ranks. Boroughs consider that this process should have been more collaborative and should have begun sooner. This could have avoided locations being identified that boroughs do not consider suitable. Boroughs also note that the need for additional taxi ranks is subject to passenger demand, which has a high level of uncertainty.